CHAPTER: Legislative Department

VINZONS-CHATO VS COMELEC

TOPIC: Constitutional organs within congress, power

FACTS:
 Petitioner Chato and respondent Renato J. Unico were among the candidates for the
lone congressional district of Camarines Norte during the May 10, 2004 synchronized
national and local elections.
 On May 14, 2004, at 11:30 a.m., the PBC proclaimed respondent Unico as
representative-elect of the lone congressional district of Camarines Norte.
 Petitioner alleged in the petition the manifestations of errors in the certificates of canvass
or election returns, questions affecting the composition or proceedings of the boards of
canvassers, or noting of objections on election returns or certificates of canvass were
allowed before the MBC. She further claimed that with all the manifest errors and
obvious discrepancies appearing on the face of the election returns, it could not be said
that the canvassing of votes in Labo reflected the true and correct number of votes that
she received in the said municipality. But the Comelec refused to do.
 On July 2, 2004, the COMELEC (First Division) ordered the suspension of the effects of
the proclamation of respondent Unico.
 On July 23, 2004, it lifted the said order on the ground that respondent Unico's
proclamation and taking of oath of oce had not only divested the Commission of any
jurisdiction to pass upon his election, returns, and qualications, but also automatically
conferred jurisdiction to another electoral tribunal.


ISSUES:
 Whether or not the court should take cognizance of Chato’s election protest. If
not, to who is this issue best addressed to?

RULING: No,
 The court should not take cognizance of Chato’s election protest for it would amount to
usurpation of the constitutionally mandated functions of the HRET.
 In an electoral contest where the validity of the proclamation of a winning candidate who
has taken his oath of office and assumed his post as Congressman is raised, that issue
is best addressed to the HRET.
o The reason for this ruling is self-evident, for it avoids duplicity of proceedings and
a clash of jurisdiction between constitutional bodies, with due regard to the
people's mandate.
 Here the Comelec did not commit grave abuse of discretion when it issued a resolution
holding that it had lost jurisdiction upon Unico’s proclamation. It demonstrated fealty to
the constitutional fiat regarding HRET.